Ampyx Cyber Blog

The Intersection of Regulation & Resilience

Ampyx Cyber Joins the E-ISAC Vendor Affiliate Program
Ampyx Arc Patrick Miller Ampyx Arc Patrick Miller

Ampyx Cyber Joins the E-ISAC Vendor Affiliate Program

Ampyx Cyber has joined the Electricity Information Sharing and Analysis Center (E-ISAC) Vendor Affiliate Program. For a services firm that sits across a wide cross-section of the electric sector, membership formalizes something we already believed: grid threat intelligence is only as good as its willingness to move in both directions.

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NERC Computational Load Standards: FERC Sets December 2026 Deadlines
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

NERC Computational Load Standards: FERC Sets December 2026 Deadlines

FERC did not accelerate NERC's timeline, it made the calendar a directive and moved registration onto the critical path. The order creates the computational load entity, sets the December 31 and March 1 deadlines, and leaves the AI Reliability Boundary, the line between what the grid must command and what it leaves to private contract, for Phase II to draw. What is settled, what is not, and what to do in the next ninety days.

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Computational Load and the Convergence Problem: What NERC's May 2026 Actions Mean for Critical Infrastructure
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Computational Load and the Convergence Problem: What NERC's May 2026 Actions Mean for Critical Infrastructure

Documented load losses approaching one thousand megawatts in seconds. A Level 3 Essential Action Alert. A final Reliability Guideline. Proposed registration of a new Computational Load Entity. NERC's May 2026 actions mark a structural shift in how data centers, hyperscale AI training, and cryptocurrency mining are treated under the North American grid reliability framework.

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Funded, Not Secured: The April 20 DPA Determinations & the Bulk Electric System
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Funded, Not Secured: The April 20 DPA Determinations & the Bulk Electric System

Two April 20 Defense Production Act determinations expand domestic capacity for grid components and large-scale energy infrastructure. Neither addresses cybersecurity. For the electric sector, NERC CIP and Order 693 standards still apply. A practitioner's view of intersections with CIP-013, CIP-014, PRC, FAC, and TPL, and why domestic capacity is not domestic assurance.

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FERC Issues Orders on Virtualization and Low Impact: What Changed and What You Need to Do
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

FERC Issues Orders on Virtualization and Low Impact: What Changed and What You Need to Do

FERC unanimously approved Order Nos. 918 and 919 on March 19, 2026, finalizing CIP virtualization standards and new low-impact BES Cyber System controls, plus an updated "Control Center" definition. All CIP-registered entities are affected. Implementation windows are 24 and 36 months respectively. Compliance programs should begin gap assessments now.

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ERO CMEP 2026: Oversight in the Age of Transformation
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

ERO CMEP 2026: Oversight in the Age of Transformation

The Electric Reliability Organization’s (ERO) 2026 Compliance Monitoring and Enforcement Program Implementation Plan (CMEP) signals a new era in how risk-based oversight keeps pace with a rapidly transforming grid. Released in October, the plan refines NERC’s compliance priorities for the coming year, retiring Incident Response as a distinct risk element and introducing Grid Transformation as a central theme.

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INSM Just Got Clearer: Key Takeaways from the NATF Guidance
Deep Dive Patrick Miller Deep Dive Patrick Miller

INSM Just Got Clearer: Key Takeaways from the NATF Guidance

NATF has released new CIP-015 INSM guidance that confirms a risk-based approach for collection points, clarifies scope around ESP boundaries, contains numerous useful reference models, and reinforces practical retention strategies. It aligns closely with our INSM playbook, especially on passive visibility, multicast deduplication, and EACMS/BCSI determinations for INSM platforms.

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Closing the Gaps: FERC Order 912 and the Future of Supply Chain Risk Management
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Closing the Gaps: FERC Order 912 and the Future of Supply Chain Risk Management

FERC Order 912 marks a shift in supply chain cybersecurity for the Bulk-Power System. It directs NERC to strengthen supply chain protections by closing gaps in risk identification, reassessment, and response, and by extending coverage to Protected Cyber Assets. Vendor data validation is encouraged but not mandated, and NERC has 18 months to deliver new or revised standards.

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Securing Tomorrow’s Grid: FERC Acts on Low Impact, Virtualization, and Supply Chains
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Securing Tomorrow’s Grid: FERC Acts on Low Impact, Virtualization, and Supply Chains

FERC’s September 2025 actions reshaped grid reliability standards by tightening security requirements for low-impact assets, adding authentication, encryption, and monitoring; new requirements and new definitions to support secure adoption of virtualization technologies; and expanding supply chain protections to cover Protected Cyber Assets and other connected systems.

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CIP-015 Clarified: Mixed-use PACS/EACMS and What’s Actually In Scope
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

CIP-015 Clarified: Mixed-use PACS/EACMS and What’s Actually In Scope

FERC Order 907-A clarifies CIP-015 on shared networks. INSM must monitor only east-west traffic used for access monitoring of EACMS and PACS. Non-CIP assets and data flows are out of scope, even in mixed-use or commingled PACS/EACMS environments. Learn practical patterns to filter collection, segment analytics, and produce audit-ready evidence.

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CIP-002-8, Decoded: Who’s In, Who’s Out Under the New 2.12
Deep Dive Patrick Miller Deep Dive Patrick Miller

CIP-002-8, Decoded: Who’s In, Who’s Out Under the New 2.12

Upcoming NERC CIP-002 grid rules change which control centers fall under stricter cybersecurity protections. This post explains the new test in plain language, who is likely covered, and when local, load-serving areas can qualify for an exception. We also share a quick checklist to help utilities document what they have today and avoid surprises later.

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CIP-015-1 INSM: A Practical Playbook
Deep Dive Patrick Miller Deep Dive Patrick Miller

CIP-015-1 INSM: A Practical Playbook

NERC CIP-015 makes east-west visibility inside the ESP mandatory. This playbook shows how to stand up INSM the right way through risk-based data feeds, ICS-aware anomaly detection, evaluation tied to incident response, and defensible evidence on a timeline to 10/1/2028 and beyond. Avoid common pitfalls and design now for the likely CIP-015-2 expansion.

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Help Shape the Future of the NERC CIP Standards
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Help Shape the Future of the NERC CIP Standards

NERC is asking for industry input on the future of CIP Standards. As part of its 2025 Work Plan, NERC has launched a survey to identify and prioritize emerging security risks to the Bulk Power System. The results will directly inform a roadmap for updating the CIP Standards to address today’s evolving threat landscape. What’s happening, why it matters, and how you can participate before the July 22 deadline.

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FERC Quietly Closes The Books on RM20-12-000
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

FERC Quietly Closes The Books on RM20-12-000

FERC has officially closed Docket RM20-12-000, ending a five-year inquiry into potential gaps in the CIP Reliability Standards. While the docket is withdrawn, the underlying concerns—data security, anomaly detection, and coordinated cyberattacks—are being addressed through recent standards like CIP-015-1 (INSM) and proposed updates to CIP-003.

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